The violations, which occurred with Cobham’s former subsidiary Aeroflex/Metelics Inc. between July 31, 2014 and Jan. 15, 2015, involved the shipment of electrical switches through distributors in Canada and Russia to Almaz Antey Telecommunications, a Russian entity on OFAC’s Specially Designated Nationals And Blocked Persons (SDN) List for allegedly violating the Ukraine Related Sanctions Regulations.
Cobham blamed the breakdown in its compliance on the failure of its third-party screening software to properly flag Almaz Antey among the transactions.
OFAC said Cobham voluntarily self-disclosed the violations and cooperated with the investigation, resulting in a reduced civil penalty. Since the violations, Cobham has acquired new screening software and increased its export compliance resources and training.
OFAC noted that Cobham also “circulated a lessons learned bulletin” to all its U.S.-based trade compliance staff that described the seriousness of the violations and urged its personnel to be tentative to any potentially controlled foreign entities seeking the company’s products.
The agency added that this case “demonstrates the importance of companies operating in high-risk industries (i.e., defense) to implement effective, risk-based compliance measures, especially when engaging in transactions involving high-risk jurisdictions.”